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State aid
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State aid
STATE-AID
International review for February 2024
Tim Sarson
Tim Sarson (KPMG) reports on recent developments that matter from around the globe, in a rare month of respite from BEPS 2.0.
International review for January 2024
Tim Sarson
Tim Sarson (KPMG) reports on a flurry of activity across the international tax world and looks ahead at what to expect in 2024.
Other cases that caught our eye: 15 December 2023
State aid: In the joined cases of Luxembourg v Commission (Case C- 451/21) and P Engie Global LNG Holdings and others v Commission (Case C- 454/21) (5 December 2023), finding that Luxembourg has granted unlawful state aid to Engie (formerly GDF...
Supplementing state aid: the EU Foreign Subsidies Regulation
Sarah Bond
,
Rob Jones
,
Gabrielle Van der Haegen
The FSR extends the Commission’s powers so that it can investigate subsidies granted by non-EU states to undertakings operating in the EU. Sarah Bond, Rob Jones and Gabrielle Van der Haegen (Freshfields Bruckhaus Deringer) explain the operation and implications of this regime.
Tax and the City review for June 2023
Mike Lane
Zoe Andrews
In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider HMRC’s updated unallowable purpose guidance, an advocate general opinion on state aid challenges to tax rulings and an Upper Tribunal case which raises some interesting points on distributions and procedural fairness.
International review for March 2023
Tim Sarson
Recent developments that matter from around the globe, reported by
Tim Sarson (KPMG).
The Fiat EU state aid case: swansong or phoenix reborn?
Pierre-Antoine Klethi
Peter Adriaansen
This judgment deals a blow to the European Commission’s state aid investigations concerning tax rulings on transfer pricing, writes
Pierre-Antoine Klethi and Peter Adriaansen (Loyens & Loeff).
UK v Commission: the General Court’s critical error
Simon Whitehead
Did the General Court place too much emphasis on legislative technique and too little on substance and effect? Simon Whitehead (Joseph Hage Aaronson) critiques the state aid decision in
UK and ITV v Commission.
Are EU state aid challenges by competitors always a ‘nuclear option’?
Paul Farmer
Simon Whitehead
Paul Farmer and Simon Whitehead (Joseph Hage Aaronson) consider how fiscal state aid issues should be addressed where the national tax provisions creating the aid are not based on a simple exemption from a standard rate but arise from differential rate regimes and asymmetric taxes.
Tax and the City review for July 2022
Mike Lane
Zoe Andrews
The General Court’s recent state aid decision and the Energy Profits Levy Bill are among the developments examined by Mike Lane and Zoe Andrews (Slaughter and May).
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7
EDITOR'S PICK
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
1 /7
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
,
Gabrielle Van der Haegen
2 /7
Misunderstanding purpose in Osmond and Allen
Thomas Chacko
3 /7
The statutory residence test: ten things we find very difficult about you
Claire Weeks
,
Aoife McCauley
4 /7
Burlington in the UT: a clearer approach
Kyle Rainsford
5 /7
Lessons on information notices and tax-related penalties from Baxendale-Walker
Matthew Greene
6 /7
Hargreaves in the Court of Appeal: a return to orthodoxy on withholding taxes?
Deepesh Upadhyay
,
Dominic Robertson
7 /7
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
Misunderstanding purpose in Osmond and Allen
Thomas Chacko
The statutory residence test: ten things we find very difficult about you
Claire Weeks
,
Aoife McCauley
Burlington in the UT: a clearer approach
Kyle Rainsford
Lessons on information notices and tax-related penalties from Baxendale-Walker
Matthew Greene
Hargreaves in the Court of Appeal: a return to orthodoxy on withholding taxes?
Deepesh Upadhyay
,
Dominic Robertson
NEWS
Read all
HMRC manual changes: 26 July 2024
Government’s ‘fiscal lock’ is welcome but ‘rather theatrical’, says IFS
EU Council reiterates concerns over UN framework
OECD’s ICAP documents
XST’s three priorities for HMRC
CASES
Read all
Centrica Overseas Holdings Ltd v HMRC
HMRC v GE Financial Investments
A Outram and another v HMRC
Other cases that caught our eye: 26 July 2024
Finanzamt T II v S
IN BRIEF
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Lease extensions and the 3% surcharge
What next for ISA fractional shares?
HMRC service standards: where next?
SDLT: residential or not?
HMRC service standards: where next?
MOST READ
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The dirty dozen
VAT on private school fees
The statutory residence test: ten things we find very difficult about you
Labour rules out return of pensions lifetime allowance
Reeves rules out emergency Budget